ML20055C723
| ML20055C723 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/1990 |
| From: | Curtiss NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9006210459 | |
| Download: ML20055C723 (5) | |
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N-O T A T I 0 N V 0 'T '{*f*g*E0 0 PDR i
RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE COMISSION
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FROM:
C0H4ISSIONER CURTISS j
SUBJECT:
SECY-90-139 - RESPONSE TO WESTINGHOUSE ELECTRIC CORPORATION ON DESIGN CERTIFICATION FOR AP600 i
X APPROVED w/ comments DISAPPROVED ABSTAIN e
NOT PARTICIPATING,_
RE0uEST Discussion COW 4ENTS:
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Commissioner Curtiss' comments on SECY-90-139:
The approach proposed by the staff in SECY-90-139 is, in my view, generally consistent with previous Commission guidance concerning the reviews of the EPRI ALWR requirements document for passive plants and individual passive plant designs.
Accordingly, with a few minor changes, I would approve the recommended course of action.
There has been considerable discussion on the question of what relationship the EPRI requirements document should have to individual vendor designs.
For passive plants, the Commission addressed this question in a Staff Requirements Memorandum of December 15, 1989, wherein the Commission set forth the following guidance:
Staff should ensure that the SER for Part III of the EPRI Requirements Document is completed prior to submitting to the ACRS the proposed licensing review bases for passive plants.
In the event that insufficient resources are available to review both Part III of the EPRI Requirements Document and the proposed passive designs, resources should be allocated first to the EPRI Requirements Document.
Staff Requirements Memorandum, SECY-89-334, item #4 (Dec. 15, 1989).
The policy behind this directive, reduced to its simplest form, is twofold:
(1) generic technical issues concerning the design of passive lants should be addressed and resolved in the context of the EPR1 requirements document; and (2) once resolved in the EPRI requirements document, this resolution should govern the staff in its review of individual vendor designs.
This directivc was carefully formulated with the objective of establishing the EPRI requirements document as the vehicle for the resolution of technical issues common to all passive plant designs, thereby ensuring that -- (1) the views and expertise of the ultimate customers, the utilities, will be brought to bear on the resolution of technical isrues; (2) technical issues common to all passive plant designs will be resolved in a uniform manner; and (3) we avoid the situation that we now face with the evolutionary plants, where significant technical issues have been addressed and resolvcd for individual vendor designs, using the licensing review basis as the vehicle for reaching an agreement.
with the vendor, prior to the. resolution of those issues in the EPRI requirements document.
With this understanding of the relationship of the EPRI requirements document to individual passive plant design reviews, I do not construe the Commission's December 15th directive as prohibiting any discussions whatsoever betweeen the staff and individual vendors on specific passive designs prior to
completion of the EPRI Passive Plant requirements document.'
Nor do I think that early interaction with the vendors will diminish the status or relevance of the EPRI requirements document.
Indeed, I view such early interaction with the vendors as an important and essential step in our ability to flush out the major technical and regulatory issues posed by passive plants, thereby enabling us to address and resolve these isspes in the EPRI requirements document in a more focused manner.
Absent such early interaction with the vendors, the staff's discussions with EPRI on a Requirements Document for passive plants will inevitably devolve into much more of an abstract exercise.
For the foregoing reasons, I approve the course of action recommended by the staff in SECY-90-139, subject to the noted clarifications.
1 I
' If nothing else, the language of the December 15th SRM, l
itself, specifically contemplates that staff discussions with individual vendors on specific passive plant designs will be going on at the same time that the staff is discussing the requirements document with EPRI.
2 The question of where to draw the line on how far staff should go in providing views to individual vendors on specific technical issues does not, in my judgment, lend itself to precise delineation.
As a general rule of thumb, though, I would l
distinguish the sort of "early dialogue" that the staff proposes i
to undertake with Westinghouse on the significant features of the AP-600 -- which I think is entirely appropriate -- from actually committing the agency to the resolution of technical issues in a particular manner or insisting that the vendor take a particular approach on an issue not yet resolved in the requirements document.
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UNITED STATES
' NUCLE AR REGULATORY COMMISSION c
WASHWJTON, D. C. 30006 7
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Mr. R. J. Slember i
Vice President and General Manager Energy Systems Business Unit i
Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230
Dear Mr. $1 ember:
I am responding to your letter of April 2,1990, in which you reiterated your request for an early safety review from the U.S. Nuclear Regulatory Commission (NRC) on the significant features of the AP600 and requested a review of the AP600 Licensing Review Basis (LRB) document in parallel with the Advanced Light Water Reactor (ALWR) Utility Requirements Document.
As a result of departures from traditional light water reactor design concepts associated with the passive Al.WR design philosophy, the staff is approaching the review of these designs in a cautious and nethodical manner in order in identify key issues and to effectively use resources.gn: %'T ;;eM -vee;a h4J g'
' Inst tne ALWH Utility Requirements Document %H4 play a significant role in the determination of the regulatory approach for passive plants.. An expeditious review of the ALWR Utility Requirements Document for passive plants will i
utilize NRC resources efficiently and should provide significant regulatory feedback to the nuclear industry.
We recognize, however, that early dialogue with the nuclear vendors regarding their specific passive designs will be an important factor in reaching regulatory decisions. Therefore, the staff will continue interactions with both Electric Power Research Institute (EPRI) and l
Westinghouse to f acilitate the formulation of regulatory positions for passive designs.
The staff recently attended meetings with EPRI, the Department of Energy (DOE),
and Westinghouse on passive ALWRs.
Staff members from the Offices of Research and Nuclear Reactor Regulation have attended meetings with the Westinghouse staff to begin significant technical interchange on. items such as planned testing programs and appropriate development of computer codes. Additionally, members of the staff will participate in the planning meetings between DOE and.
Westinghouse to ensure that the NRC stays actively involved as the design c
progresses.
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The staff will review the AP500 LRB in parallel with the-ALWR Vtility Require-l ments Document and provide comments to Westinghouse before the completion of the ALWR Vtility Requirements Document review L;;;r, t: : r;r; n-; ht:
the LRB will not be forwardec to the ACRS for comment until
- .ie;;cylequirementsDocumentreviewiscomplete.
the ALWR Utility This will ensure tX>b seh l+s Vt1 der $Wi ihd y ttsw % gcgj y jfr gorggggg;he co.ded d*Mn 4 MA5IK fkk w be a(m eee we. A&ested al asplpern ke. Me ni a Mr us
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Hr. R. J. Slember 2-l dcasform b l
that the LRB willA h the technical policy decisions resultinj from the ALWR Utility Requirements Document review.
I am confident that tltis process will support Westinghouse's intent to submit the standard safety analysis report in June 1992.
Sincerely, James M. Taylor Executive Director for Operations f
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